Postgraduate applicant privacy policy

Where we refer in this policy to your ‘personal data’, we mean any recorded information that is about you and from which you can be identified. It does not include data where your identity has been removed (anonymous data).

Where we refer to the ‘processing’ of your personal data, we mean anything that we do with that information, including collection, use, storage, disclosure, deletion or retention.

The University of Oxford^[2] is the “data controller" for the information that we obtain from you or others as a result of your application for graduate study. This means that we decide how to use it and are responsible for looking after it in accordance with the UK GDPR.

Access to your data will be provided to and shared between the academic and support staff, including those based in the University’s colleges^[1], who need to view it as part of their work in carrying out the purposes set out in Section 6. We also share it with the third parties described in section 8.

^[2] The University’s legal title is the Chancellor, Masters and Scholars of the University of Oxford

The information we hold about you may include the following:

• Personal details such as name, title, address, telephone number, email address, date of birth, legal sex and gender identity, ID photograph (included within received documents), marital status, information about household income, and details of dependants;
• Education and employment information (including the school(s), sixth form college(s) and other colleges or universities you have attended and places where you have worked, the courses you have completed, dates of study and examination results);
• Other personal socio-economic background information collected during the admissions process, e.g. whether you have been in care, whether you have caring responsibilities, whether you are estranged, homeless or are a refugee/have experienced displacement, details of your parents’ occupation and education;
• Correspondence to or from the University, or a College, during the admissions process;
• Visa, passport and immigration information;
• Funding and financial support information;
• Your feedback on the application process and university services collected through surveys such as (but not limited to) those sent to applicants and offer-holders;
• Attendance records at University organised recruitment events, and photographic data of such events captured for the purpose of live streaming and/or future publicity materials;
• Information about your use of our IT, information and communications systems, including your communication preferences and website interaction (cookies and similar technologies);
• Information we obtain from third parties relevant to verifying information supplied in your application (e.g. from referees or previous educational institutions). 

We may also process the following "special categories" of more sensitive personal data:

• Information about your race or ethnicity, sexual orientation and religious beliefs;
• Information about your health, including any disability and/or medical condition;
• Information about criminal convictions and offences, including proceedings or allegations.

Special category data will only be used in accordance with section 7.

We collect the vast majority of the information directly from you, such as during your registration to use our online application form, through the application process and after you submit your application. We may also collect additional information from third parties and their staff, including referees, former schools, colleges and universities, and government departments and agencies. We may also collect information about you which is in the public domain.

Before you submit your application, we process your data in order to administer our application process, such as to investigate a problem reported by you. Once you submit your application, we process your data for the purpose of processing and assessing your application for study, and for purposes related to your application, such as assessing your eligibility for funding and your financial status or to verify information you have supplied to us in your application (e.g., regarding previous qualifications).

We set out below those circumstances where it is necessary for us to process your data. (These circumstances are not mutually exclusive; we may use the same information under more than one heading.)

6.1 Because we have a contractual obligation to consider your application

Information processed for this purpose includes the data listed in section 4 above.

We also need to process data under this heading where the University is working with a third party in order to offer you services, for example, those offered by Colleges, sponsors (such as research councils), other universities or scholarship benefactors. See section 8 for a fuller list of examples of third-party sharing.

6.2 Where we need to comply with a legal obligation

Information processed for this purpose includes, but is not limited to, information relating to the monitoring of equal opportunities and information provided to regulatory bodies including the General Medical Council, the Office for Students and the OIA. We are also required by law to provide data to the Higher Education Statistics Agency (HESA) which shares information with public authorities that are required to carry out their statutory and/or public functions.

6.3 Where it is necessary to meet our legitimate interests

We also need to process your data in order to meet our legitimate interests or the legitimate interests of others. Examples include, but are not limited to, the following:

• sending you communications containing information on how to complete your application;
• monitoring and researching equal opportunities and admissions statistics;
• inviting you to take part in applicant surveys or enabling third parties to conduct applicant surveys on our behalf;
• notifying you of changes to course information;
• sending specific communications to applicants likely to be affected by major incidents (e.g. natural disasters or conflicts in a specific country/region).

6.4 Where we have your consent

There may be situations where we ask for your consent to process your data, for example the socio-economic questions in the application form (where a "Prefer not to say" option is available) and pre-application communications for student recruitment purposes (you will always be able to opt out of receiving such communications).

If you fail to provide personal information under 6.1 or 6.2 above

If you fail to provide certain information when requested under the circumstances described in 6.1 and 6.2 above, we may not be able to meet our contractual obligation to consider your application or to comply with our other legal obligations.

Change of purpose

We will only process your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another related reason, and that reason is compatible with the original purpose. If we need to use your data for an unrelated purpose, we will seek your consent to use it for that new purpose.

Please note that we may process your data without your knowledge or consent where this is required or permitted by law.

Special category data and criminal conviction data require a higher level of protection. Listed below are examples of processing activities that we regularly undertake in respect of these types of data. In addition to the activities listed below, it may sometimes be necessary to process this sort of information for exceptional reasons, for example, because it is necessary to protect your vital interests or those of another person or for safeguarding purposes. We may also process your special category data to identify your eligibility for certain scholarships (e.g., Academic Futures scholarships, female only STEM scholarships) or certain initiatives to improve access to the University for under-represented and/or disadvantaged students as a proportionate means to achieve a legitimate aim.

Note that where special category data may need to be shared, we will seek to anonymise or pseudonymise it (except in cases where the legitimate aim of the initiative could not be achieved by use of anonymised or pseudonymised data).

7.1 Health (including disability)

We will process data about your health where it is necessary to make reasonable adjustments for disability (e.g., to arrange access for interviews) and/or to monitor equal opportunities. This processing is necessary to meet our legal obligations.

7.2 Criminal conduct

Data about relevant criminal convictions, including whether you have such a conviction, is gathered during the process of applying for a course with us once you have been offered a place. Data about barring decisions will only be collected if you have applied for and been accepted onto certain courses, and where we are legally required to do so. Processing of this nature is carried out in order to protect our legitimate interests including to protect members of the University community from a foreseeable risk of harm. For certain courses this processing is also necessary to meet our legal obligations. Such processing will be subject to suitable safeguards.

7.3 Racial or ethnic origin, sexual orientation and religious belief

Data about your racial and ethnic origin will only be processed where you have volunteered it for the purposes of:

• Identifying your eligibility for certain scholarships or initiatives (e.g., guaranteeing an interview to candidates in certain groups who meet academic criteria or to implement the objectives of the University’s Graduate Student Access Strategy, etc.), in accordance with our legitimate interests;
• Monitoring participation and increasing the number of applications from under-represented and/or disadvantaged groups at the University of Oxford through marketing, outreach and support activities to meet the University’s strategic aims and objectives; and
• Meeting our statutory obligations under equality and/or other legislation.

Data about your religious belief or sexual orientation will only be processed where you have volunteered it for the purposes of:

• Meeting our statutory obligations under equality and/or other legislation;
• Monitoring participation and providing support to meet the University’s strategic aims and objectives.

This processing is considered to meet a substantial public interest, and will be subject to suitable safeguards.

In order to perform our contractual and other legal responsibilities or purposes, we may, need to share your information with the following types of organisation:

1. Colleges (including Private Permanent Halls (PPHs), in order to support your college placement (where applicable) and enhance your student experience;
2. External organisations providing services to us, for example qualification verification services, and our enquiry management and plagiarism detection systems;
3. External organisations offering University-sponsored services including student surveys;
4. The governmental departments or agencies responsible for immigration and student loans;
5. Third parties including your former employer(s) or educational establishment(s) to obtain a reference or to verify the accuracy of a reference or other information you have submitted with or in support of your application;
6. If you have or are seeking a particular relationship with a third party, for example, because of an exchange scheme;
7. Sponsors or benefactors of funding and financial support;
8. Other Higher Education institutions as part of formal partnerships;
9. The Office for the Independent Adjudicator (OIA);
10. Where information is shared with third parties, we will seek to share the minimum amount necessary.

All third-party service providers that process data on our behalf are required to take appropriate security measures to protect your data in line with our policies. We do not allow them to use your data for their own purposes. We permit them to process your data only for specified purposes and in accordance with our instructions.

There may be occasions when we transfer your data overseas, for example, to obtain a reference or to verify information in your application. Such transfers will only take place if one of the following applies:

• the country receiving the data is considered by the UK to provide an adequate level of data protection, this includes countries in the European Economic Area;
• the organisation receiving the data is covered by an arrangement recognised by the UK as providing an adequate standard of data protection;
• the transfer has your consent;
• the transfer is necessary for the performance of a contract with you or to take steps requested by you prior to entering into that contract;
• the transfer is necessary for the performance of a contract with another person, which is in your interests;
• the transfer is governed by approved contractual clauses; or
• the transfer is necessary for important reasons of public interest.

We have put in place measures to protect the security of your information. Details of these measures are available from the University’s Information Security website.

Third parties that process data on our behalf will do so only on our instructions and where they have agreed to keep it secure.

We will retain your data only for as long as we need it to meet our purposes, including any relating to legal, accounting, or reporting requirements. Details of the retention periods for different types of student data are available here.

If you enrol as a student, your data will be processed in accordance with our student privacy policy which is available here.

Under certain circumstances, by law you have the right to:

• Request access to your data (commonly known as a “subject access request"). This enables you to receive a copy of your data and to check that we are lawfully processing it.
• Request correction of your data. This enables you to ask us to correct any incomplete or inaccurate data we hold about you.
• Request erasure of your data. This enables you to ask us to delete or remove your data in certain circumstances, for example, if you consider that there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your data where you have exercised your right to object to processing (see below).
• Object to processing of your data where we are relying on our legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your data for direct marketing purposes.
• Request the restriction of processing of your data. This enables you to ask us to suspend the processing of your data, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your data to another party.

Depending on the circumstances and the nature of your request it may not be possible for us to do what you have asked, for example, where there is a statutory or contractual requirement for us to process your data and it would not be possible to fulfil our legal obligations if we were to stop. However, where you have consented to the processing (for example, where you have asked us to send you certain types of communication), you can withdraw your consent at any time, by emailing us at [email protected]. In this event, we will stop the processing as soon as we can. If you choose to withdraw consent it will not invalidate past processing and it may impact our ability to provide particular additional services to you. Further information on your rights is available from the Information Commissioner’s Office (ICO).

If you want to exercise any of the rights described above or are dissatisfied with the way we have used your information, please contact the University’s Information Compliance Team at [email protected]. The same address can be used to contact the University’s Data Protection Officer. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of the UK GDPR. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

If you remain dissatisfied, you have the right to lodge a complaint with the ICO at https://ico.org.uk/concerns/.

It is important that the data we hold about you is accurate and current. You can access, amend and delete your data yourself until the point at which you submit your application to the University. Please keep us informed of any changes after you submit your application.

We reserve the right to update this privacy policy at any time, and will seek to inform you of substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.